Privacy Policy

This Privacy Notice for Тракер Тех ООД (Tracker Tech Ltd.), a limited liability company registered in the Republic of Bulgaria under Unified Identification Code (UIC/ЕИК) 208781243 and VAT No. BG208781243, doing business as TollTracker ("Tracker Tech," "TollTracker," "we," "us," or "our"), describes how and why we access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

Visit our website at tolltracker.eu, or any website of ours that links to this Privacy Notice;
Download and use our mobile application (TollTracker) on iOS or Android;
Use our interactive map, receive road-safety and traffic-enforcement alerts, or use any related feature; or
Interact with us in other related ways, including sales, marketing, support, or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. Tracker Tech Ltd. is the controller responsible for the decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions, contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice. You can find more detail on any topic by using the table of contents below or scrolling to the relevant section.

•What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us, the choices you make, and the features you use.
•Do we process sensitive personal information? No. We do not process sensitive personal information, such as data revealing racial or ethnic origin, political opinions, religious beliefs, health, or sexual orientation.
•Do we collect location data? Our mobile app uses your device location to warn you about speed cameras, average-speed sections, enforcement and restricted zones, and road hazards ahead of you. Location is processed to deliver alerts; it is not used to build a profile of your journeys, and it is never sold.
•Do we collect information from third parties? We may receive information from payment and subscription providers, authentication providers, analytics and advertising partners, and public sources.
•How do we process your information? To provide, improve, and administer the Services, deliver alerts, process subscriptions, communicate with you, prevent fraud, and comply with the law. We process your information only where we have a valid legal reason to do so.
•When and with whom do we share information? Only with the service providers and in the situations described in this Notice. We never sell your personal information.
•How do we keep your information safe? We use appropriate organizational and technical measures. However, no electronic transmission or storage can be guaranteed to be 100% secure.
•What are your rights? Depending on your location, applicable data protection law (including the GDPR) may grant you rights over your personal information, such as access, rectification, erasure, restriction, portability, and objection.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide when you register for the Services, purchase a subscription, express interest in our products, participate in activities within the Services, or otherwise contact us.

Personal information provided by you. Depending on how you use the Services, this may include:

names;
email addresses;
usernames;
passwords and authentication data;
billing details;
subscription and purchase history;
support correspondence.

Sensitive information. We do not process sensitive personal information.

Payment and subscription data. When you buy a subscription, payment is processed by our providers — Apple App Store and Google Play (in-app purchases), and RevenueCat, Stripe, and Outseta (web purchases). We receive confirmation of your purchase and your subscription status, but we do not collect or store full payment-card numbers ourselves. Their privacy policies apply, including https://www.revenuecat.com/privacy, https://stripe.com/privacy, https://www.outseta.com/privacy-policy, https://www.apple.com/legal/privacy and https://policies.google.com/privacy.

Social login data. We may let you register or sign in using a third-party account (for example Google or Apple). If you choose this, we receive certain profile information as described in Section 6.

Mobile application data. If you use the TollTracker app, with your permission we may process the following:

Location information. We request access to your device location (while using the app or in the background) so we can warn you about speed cameras, average-speed sections, traffic-enforcement and restricted zones, and road hazards ahead of you. Location is processed on your device to deliver these alerts; we do not use it to build a profile of your journeys, and we do not sell it. You can disable location access at any time in your device settings, though this will disable the core alerting features.
Push notifications. We may request to send you push notifications about alerts, your account, or your subscription. You can turn these off in your device settings.
Mobile device data. Device identifiers, operating system and version, app version, language, and diagnostic data used to operate the app, deliver alerts, and troubleshoot problems.

All personal information you provide to us must be true, complete, and accurate, and you must notify us of any changes.

Information automatically collected

In short: Some information — such as your IP address and browser or device characteristics — is collected automatically when you use the Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not usually reveal your specific identity but may include device and usage data, such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and information about how and when you use the Services. This information is primarily needed to maintain the security and operation of our Services, and for internal analytics and reporting.

Log and Usage Data. Service, diagnostic, usage, and performance information automatically collected by our servers when you access the Services, such as IP address, browser type and settings, device information, actions within the Services, and error reports.
Device Data. Information about your computer, phone, tablet, or other device, such as IP address, device and application identifiers, browser type, hardware model, internet or mobile service provider, operating system, and configuration.
Location Data. Data about the location of your device, precise or approximate. The amount collected depends on the type and settings of the device you use. You can opt out by denying access or turning off the location setting on your device, though this may limit certain features.

Google services and APIs

We use a number of Google services to operate the Services, including Google Sign-In and Firebase (for authentication and push notifications), Google Analytics (for website usage analytics), and Google Play billing (for purchases on Android). Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including its Limited Use requirements. Please note that the maps in our Services are rendered using Mapbox, not Google Maps. By using our Services you also agree to be bound by Google's Terms of Service and Privacy Policy.

Information collected from other sources

In short: We may collect limited data from payment providers, analytics and advertising partners, social platforms, and public sources.

We may receive information about you from payment and subscription providers (to confirm your purchases), from analytics and advertising partners, and from social platforms if you interact with us through your social account. We use this information to operate, secure, and improve the Services and to keep our records accurate.

2. HOW DO WE PROCESS YOUR INFORMATION?

In short: We process your information to provide, improve, and administer our Services, to communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.

To facilitate account creation, authentication, and account management, and to keep your account in working order.
To deliver and operate the Services, including road-safety and traffic-enforcement alerts.
To process your subscription and payments and to manage your orders.
To respond to your inquiries and provide support.
To send you administrative information and, where permitted, marketing or promotional communications.
To improve, personalize, and analyze the Services and understand how they are used.
To protect the Services, prevent fraud and abuse, and maintain security.
To comply with our legal obligations and to enforce our terms.
To protect the vital interests of an individual, for example to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In short: We process your personal information only when we have a valid legal basis to do so under applicable law.

The General Data Protection Regulation (GDPR) requires us to explain the valid legal bases we rely on to process your personal information. We may rely on the following legal bases:

Consent. We may process your information if you have given us permission for a specific purpose. You can withdraw your consent at any time.
Performance of a contract. We may process your information to provide the Services you have requested, to process your subscription, and to fulfill our obligations to you.
Legitimate interests. We may process your information where it is necessary for our legitimate interests, such as securing and improving the Services, analytics, and marketing to our existing customers, provided those interests are not overridden by your rights.
Legal obligations. We may process your information where necessary to comply with our legal obligations, such as accounting and tax requirements or responding to a lawful request from a public authority.
Vital interests. We may process your information where necessary to protect your vital interests or those of a third party.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In short: We share information with the service providers we rely on to run the Services and in the specific situations described below. We never sell your personal information.

We may share your personal information in the following situations:

Service providers (processors). We share information with the vendors and service providers who perform services for us under contract and only as needed to provide the Services. These fall into the following categories: subscription and payment processing, authentication and push notifications, email delivery, analytics, advertising, map rendering, and hosting and infrastructure. Where relevant, we name specific providers elsewhere in this Notice, such as our payment providers and the Google services we use.
International transfers. Some of our providers are located outside the European Economic Area, for example in the United States. Where we transfer personal data internationally, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses and/or the EU–US Data Privacy Framework.
Business transfers. We may share or transfer your information in connection with, or during negotiations of, a merger, sale of company assets, financing, or acquisition of all or a portion of our business.
Legal requirements. We may disclose your information where required to do so by law or in response to a valid request by a public authority, or where necessary to establish, exercise, or defend our legal rights.
With your consent. We may share your information for any other purpose with your consent.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In short: Yes, we use cookies and similar technologies to operate the website, remember your preferences, and, with your consent, for analytics and advertising.

We use cookies and similar technologies (such as web beacons and pixels) to keep the website secure and working, to remember your choices (including your language and cookie preferences), and to understand how the Services are used. On our website we present a cookie banner that lets you accept or reject non-essential cookies and manage your preferences.

With your consent, we also allow selected third parties to use tracking technologies on our website for analytics and advertising, including measuring campaign performance and showing you relevant ads. You can change or withdraw your consent at any time through the cookie preferences on the website.

Analytics and advertising

We use Google Analytics to understand and improve how our Services are used, and we may use Meta (Facebook) advertising tools to measure and deliver advertising. These providers may set their own cookies and process usage data as independent controllers or as our processors, depending on the feature.

You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on, and you can manage advertising preferences in your Google and Meta account settings. For more information, see Google's Privacy Policy at https://policies.google.com/privacy and Meta's Privacy Policy at https://www.facebook.com/privacy/policy.

6. HOW DO WE HANDLE SOCIAL LOGINS?

In short: If you choose to register or log in using a social or third-party account, we may receive certain profile information about you.

Our Services may allow you to register or log in using a third-party account, such as your Google or Apple account. When you do, we receive certain profile information from that provider, which typically includes your name and email address, and may include other information you have made available. We use the information we receive only for the purposes described in this Notice. We are not responsible for how the third-party provider uses your data. We recommend reviewing their privacy notice and adjusting your settings.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In short: We keep your information for as long as necessary for the purposes set out in this Notice, unless a longer retention period is required or permitted by law.

We will keep your personal information only for as long as necessary for the purposes set out in this Notice, unless a longer period is required or permitted by law (for example, for tax, accounting, or other legal requirements). When we no longer have a legitimate need to process your information, we will either delete or anonymize it.

If deletion is not possible (for example, because your information is stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In short: We aim to protect your personal information through appropriate organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational measures designed to protect the personal information we process. However, despite our safeguards, no electronic transmission over the internet or storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that unauthorized third parties will never be able to defeat our security. You access the Services at your own risk, and you should only do so within a secure environment.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In short: In the European Economic Area, the United Kingdom, and other regions, you have rights that give you greater access to and control over your personal information.

Under applicable data protection law, you may have the right to: (i) request access to and a copy of your personal information; (ii) request rectification or erasure; (iii) restrict the processing of your personal information; (iv) where applicable, data portability; and (v) object to the processing of your personal information. You can make such a request by contacting us using the details in Section 12. We will consider and act upon any request in accordance with applicable data protection law.

If you are located in the EEA or the UK and believe we are unlawfully processing your personal information, you also have the right to lodge a complaint with your local data protection supervisory authority. In Bulgaria, this is the Commission for Personal Data Protection (Комисия за защита на личните данни) — see https://www.cpdp.bg.

Withdrawing your consent

Where we rely on your consent to process your personal information, you have the right to withdraw it at any time by contacting us using the details in Section 12. Withdrawing your consent will not affect the lawfulness of processing carried out before its withdrawal, nor processing carried out on a legal basis other than consent.

Opting out of marketing communications

You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send, or by contacting us using the details in Section 12. We may still send you service-related messages that are necessary to administer your account and the Services.

Account information

To review or change the information in your account, or to close your account, you can:

Upon your request to close your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and similar technologies. Most browsers accept cookies by default. You can usually set your browser to remove or reject cookies, but this may affect certain features of the Services.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and applications include a Do-Not-Track (DNT) feature you can activate to signal your preference not to have your online activity tracked. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you in a revised version of this Notice.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In short: Yes, we will update this Notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Notice. If we make material changes, we may notify you either by prominently posting a notice or by directly sending you a notification. We encourage you to review this Notice regularly to stay informed about how we protect your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this Notice, you may email us at [email protected] or contact us by post at:

Тракер Тех ООД (Tracker Tech Ltd.) UIC 208781243 · VAT BG208781243 Sofia, Bulgaria [email protected]

Тракер Тех ООД (Tracker Tech Ltd.) is established in the European Union (Bulgaria) and acts as the data controller for your personal information. For any matter relating to the processing of your data, please contact us at [email protected].

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Depending on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, to receive details about how we have processed it, to correct inaccuracies, or to delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To make such a request, please email [email protected] with the subject "Data Subject Access Request."